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Japan Updates Food Contact Materials Positive List

The Ministry of Health, Labor, and Welfare (MHLW) in Japan has recently announced updates to its positive list of substances permitted for use in food contact materials (FCMs). These changes, which will be enforced from June 1, 2025, have significant implications for brands, retailers, manufacturers, and distributors of food contact material products in Japan.

Key Points:

  1. Safety Evaluation and Approval: The positive list system ensures that only substances that have been evaluated for their safety can be used in food utensils, containers, and packaging. The updated list includes three documents: polymers, additives, and essential monomers. Each document provides detailed information such as chemical names, CAS registry numbers, and use requirements in both Japanese and English.

  2. Similarity to EU List: The positive list system in Japan aligns with the European Union's (EU) list. This means that only substances included in the positive lists can be utilized for manufacturing food contact materials and articles.

  3. Compliance and Record-Keeping: Under the amended Regulations for Enforcement of the Food Sanitation Act, companies are required to comply with both the positive list system and the negative list system. Compliance involves using compliant materials/substances for production and conducting product testing specific to the product type and materials. Additionally, companies must provide customers with usage and safety information and maintain records related to production and supply.

The regulatory update on Japan's positive list for food contact materials underscores the importance of compliance for businesses involved in selling, supplying, manufacturing, and distributing such products. By ensuring adherence to the updated positive list, companies can avoid penalties and protect their reputation. Furthermore, implementing robust record-keeping systems and providing accurate usage and safety information to customers will enhance transparency and reinforce consumer trust.

To ensure compliance for food packaging and containers, it is recommended to have food contact materials testing conducted by a reliable third-party provider such as QIMA.

For the latest updates on product safety standards and regulations, visit Regulatory Updates. We provide regular updates to help you stay informed and ensure compliance with the latest requirements.

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